[Comments-subsequent-procedures-22mar17] Subsequent Procedures PDP CC2 Response

[Mark Carvell]

Mark Carvell, United Kingdom Representative on ICANN’s Governmental Advisory Committee, submits the following responses to the CC2 questionnaire.

Application fees

Q 1.4.1  The same break even and cost neutral  principle should be applied to any subsequent new gTLD process, i.e. the process to expand further the domain name system should not be driven by the aim of generating additional revenues for the ICANN community. 

Q 1.4.2  and 1.4.3  There was no clearly understood or predictable market expectation of the volume of take up for the current round with the result that the volume of fees received far exceeded the basis used for determining the US$185k fee level.
This level was considered appropriate for recovering the historical costs of preparing for the round and secondly setting a bar to deter frivolous and wholly inadequately prepared and under-resourced applications.
For a future process, the historical costs will be lower in view of the experience and established and fully developed mechanisms from the first fully open round. The fee can as a consequence be considerably lower - 
perhaps by 50% while still maintaining a bar sufficient to ensure that all applications received are coherent and worth dedicating resources fro evaluation and processing.

Q 1.6.1 The principal problem that would arise from a continuous process is that all applications would be treated on a first come first serve basis that would put some applicants for the same strong at a serious disadvantage in comparison with wholly commercialised 
applicants with ready access to finance and human resources to develop a proposal quickly to gain first advantage. The process for resolving string contention by comparative evaluation and application prioritisation eligibility for example in the case of community-based 
applications, would not be practicable with an ongoing process, unlike in the case of a defined window for an application round. The three months window provided for the current round with adequate notice appears to have worked well.

Q 1.7.1 and 1.7.2  The prioritisation draw of the current round appeared to work well. If a round mechanism is not adopted next time, it should nonetheless be possible to inaugurate the next process with a prioritisation draw or similar mechanism.
With more effective communication of the opportunity and building on current experience of successful IDNs, prioritisation of IDNs should help to increase the number of IDNs to a level of take-up exceeding the very disappointing low percentage level of the currne round.
This should be a key objective of the next process to expand the global domain name system.

Q 1.9  The expansion in the number of national and regional multi-stakeholder Internet Governance Fora (IGFs) provide valuable outreach opportunities and close-to-market hub modalities for promoting the next new gTLD application process or round to stakeholder 
communities worldwide including least developed economies and small island developing states for whom the global digital economy increasingly provides unprecedented opportunity for economic and social growth. ICANN has an increased opportunity to contribute to 
sustainable development goals through expansion of the domain names system.

Q 3.3  The poor performance and management of the CPE process and related mechanisms was a major failure in the current round. The independent experts commissioned by the Council ofEurope analysed the issues and experience of applicants and has made a coherent 
and though set of recommendations to correct these mistakes so that communities wishing to express themselves and assemble freely through a gTLD will be able in a future process to apply with confidence and in the knowledge that they are supported by the ICANN stockholder community.

Q 4.3.3 The PDP WG should review the desirability of a continuous and rigorous vetting process for applicants during the prolonged period of application, evaluation and delegation when ownership and lead persons for the application may change, with the aim of avoiding any 
possible risk of criminality gaining a foothold in the domain name system/


Mark Carvell
Head, Global Internet Policy
Department for Culture, Media and Sport
United Kingdom Government

22 May 2017



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